Two federal decree-laws changed UAE VAT and tax procedures from 1 January 2026: Federal Decree-Law 16 of 2025 (VAT) and Federal Decree-Law 17 of 2025 (Tax Procedures). Most of the changes are tidy-ups. One has a hard deadline that is only weeks away.
The deadline: old refunds must be claimed by 31 December 2026
Refund claims now have a five-year limit. Excess input VAT has to be used or claimed within five years of the end of the tax period it arose in. For balances whose five years have already run out, or will run out within a year, the law gives a one-off transitional window to claim by 31 December 2026. In practice, that covers credits going back to the first years of VAT.
If your VAT account carries an old credit balance, check it now. After the deadline, the money is gone.
What else changed
- No more self-invoices under reverse charge. Businesses accounting for VAT on imported services or goods no longer need to issue themselves a tax invoice. You still need the supplier's invoice and supporting documents.
- Input tax denied for supplier fraud. The FTA can refuse input VAT where a supply is linked to tax evasion and you knew, or should have known. Not checking your suppliers counts against you, so supplier due diligence is now a tax control, not just good practice.
- A clearer five-year audit window. The FTA's general time limit to audit and assess is five years, with set exceptions. A refund claim made late in that window gives the FTA extra time to review it.
- Voluntary disclosures narrowed. Many corrections now go through the next return instead of a separate disclosure. Read the FTA's current guidance on which errors still need one.
What to do before year end
- Pull your VAT credit history by period and identify anything at risk of lapsing.
- Confirm your reverse-charge process still keeps the right documents now that the self-invoice is gone.
- Put a basic supplier-verification step in place: trade licence, TRN check, and a record that you did it.
How iConsult can help
We review VAT positions, prepare refund claims and build the supplier checks that support your input tax. See our audit readiness and tax services or book a free consultation.
This article is general information, not legal or tax advice. It reflects the rules as we understand them on the date shown; laws and guidance change, so check the current position or talk to us before you act.